Best Start Grant: analysis of consultation responses

Impact Assessments

The remainder of the consultation document sought views on the potential impacts of the BSG draft regulations in relation to:

• the Equality Impact Assessment ( EQIA);
• the Child Rights and Welfare Impact Assessment ( CRWIA); and
• the Business and Regulatory Impact Assessment ( BRIA).

BSG Equality Impact Assessment

The Equality Impact Assessment identifies potential impacts based upon age, disability, sex, pregnancy and maternity, race, and religion or belief, as well as for other groups such as foster carers, kinship carers, adoptive parents, young care leavers, and the gypsy/traveller community. Views were sought on any additional impacts on groups already considered, and/or any evidence as would relate to impacts based on gender reassignment or sexual orientation.

Q9a. Are you aware of any impacts we have not identified?

Response	Number	Percentage
Yes	8	16%
No	22	43%
Don't Know	4	8%
No quantitative response	17	33%
Total	51	100%

Comments focussed on perceptions of challenges, shortcomings or gaps in the provision or potential consequences of the grant, rather than focusing on equality related impacts per se.

Three respondents raised issues relating to asylum seekers and refugees, and suggested the impacts on this group required further attention. They felt that they were particularly vulnerable and 'in need', but that the current draft regulations for the BSG did not do enough to assist them, or might indeed exclude them from eligibility:

"Asylum seekers are currently excluded from SSMG and BSG as persons who are subject to immigration control. They are a group desperately in need of support and consideration ought to be given to asylum support as a qualifying grant." (Organisation)

"The consultation identifies that people who have been granted refugee status often face significant delays in accessing benefits. This can significantly heighten their risk of experiencing poverty and destitution, and we would welcome any efforts… to address this gap in order to allow refugee families to access the grant as quickly as possible. While we recognise that immigration legislation acts as a constraint upon the policy options available, we are concerned that one group of people who are highly likely to experience poverty - people seeking asylum - will not be eligible for the grant. Particularly in the case of people seeking asylum who have no recourse to public funds, there is a heightened risk of destitution, and by extension a heightened risk of trauma and of detrimental health impacts on both mothers and their children." (Organisation)

Two respondents discussed the potential impact of providing cash payments to families as something which may impact across different demographic groups, with one specifically highlighting potential impacts on families where there are drug or alcohol addictions. A suggestion was made that additional support may be necessary for some to ensure there are no negative consequences of receiving cash payments and/or that the monies are spent as intended:

"There may be an issue in some cases with the potential impact that a lump sum payment, of between £250 and £600, could have on parents/households with addiction issues. Perhaps consideration should be given to whether or not some households will require support to ensure that the grant does not have a negative impact on the households and that it is spent as intended by the policy objectives." (Organisation)

One respondent also identified a gap in the provision for new born babies with disabilities, and noted the potential impact of not being assisted by either the DLA or BSG benefits, while another suggested there should be consideration for additional or increased payments for disabled children to help with costs incurred as a result of the disability:

"Where a parent has a disabled new born child there is no access to DLA at the time of birth. Entitlement to DLA begins after the passage of the three month qualifying period. There may be additional needs for the child from birth that are not addressed by either DLA or the Best Start Grant." (Organisation)

Impacts on dignity and respect in relation to the re-determination process in particular were also highlighted by one respondent:

"[We] would highlight that there is potential for a "play on words" interpretation of the draft regulations, that the mandatory reconsideration practice is simply being re-named as "re-determination". At this time it was challenging to see any difference in practice… particularly as any re-determination will also be undertaken by a member of staff from within the same Agency. It is not unreasonable to suggest that the impact of this interpretation undermines the Government's commitment to dignity and respect." (Organisation)

One respondent felt that greater consideration was required for kinship carers, foster carers and adoptive parents who already have children within the household - they felt that they should not get the lower rate of BSG for subsequent children. This respondent also recommended that the opportunity should be taken to develop a marker to identify those with care experience (with consent) which could assist in providing them with higher levels of support:

"The Department for Work and Pensions introduced a marker to identify care leavers on the Labour Market System to ensure they received better, more tailored, support. By October 2014, a total of 3,162 care leavers had self-identified and were visible on the system. To date, there is no such system for Universal Credit. There is an opportunity to consider the potential advantages of introducing this in the system as a mechanism to provide a higher level of support." (Organisation)

Another respondent noted that the distinction made within the regulations between young parents in education and those out of education may be perceived to be negative:

"The proposed distinction between parents in and out of education (payment to grandparent) might be a negative one." (Individual)

One organisation highlighted the potential for low uptake of the BSG as a result of a lack of awareness of the availability and/or entitlement to benefits, and disengagement, stigma, and perceived 'punishing practices' of the social security system. They stressed that effective promotion/communication of the BSG would be necessary, as well as ensuring the process was as simple as possible.

Finally, one respondent was against the proposal to provide benefits to support any more than two children, while another felt that the increased provision under the BSG was unnecessary and that the current SSMG rules and provision, combined with the Scottish Government's baby boxes ^[3] , were sufficient.

Other more general views were put forward that any new changes such as the introduction of the BSG needed to remain cognisant of equalities when being developed and implemented and that it was important always to engage service users in the moving forward of plans (including monitoring of effectiveness in the future). Raising awareness of the new grant and ensuring that everyone who is eligible is made aware and encouraged to apply is key, it was suggested. Special consideration should be given to those most vulnerable or at risk, including care leavers and women in abusive relationships, to ensure that equity is achieved.

Q9b. Are you aware of any evidence relevant to the BSG policy and gender reassignment and/or sexual orientation?

Response	Number	Percentage
Yes	0	0%
No	32	63%
Don't Know	3	6%
No quantitative response	16	31%
Total	51	100%

No respondents were aware of any relevant evidence related to the BSG policy and gender reassignment and/or sexual orientation, either as identified in the quantitative responses or via qualitative comments.

BSG Child's Rights and Wellbeing Impact Assessment

Linked to the EQIA, the BSG Child's Rights and Wellbeing Impact Assessment ( CRWIA) also highlighted that the children of young parents, children in lone parent households, children in lower income households, children living in poverty, children with a disability, or children living as part of a bigger family will all benefit positively from the BSG. It was also noted that children in families where parents have repartnered, and children who are born as part of a multiple birth would also benefit from the BSG.

Q10. Are you aware of any impacts on children's rights and wellbeing which are not identified here?

Response	Number	Percentage
Yes	6	12%
No	27	53%
Don't Know	2	4%
No quantitative response	16	31%
Total	51	100%

Although a number of qualitative comments were provided at this question, some again related to perceived challenges, shortcomings or gaps in the provision or potential consequences of the grant more generally, rather than focusing on impacts on the child's rights and wellbeing more specifically. Although linkages can be inferred, these were not often made explicit in the responses.

Two respondents again highlighted the risks associated with the monies not being used as intended, with one suggesting tokens or vouchers would be more appropriate, and the other specifically highlighting the risks where payments are made to the grandparents rather than directly to young parents. Two others also requested that the first child rate was applied for subsequent children following a large age gap (one suggested five years while another suggested 10 years) as new equipment would likely be necessary, with one of these respondents also seeking this provision for migrant families who arrive in the UK following the birth of existing children, again as it is likely they will have to replace all previously owned baby equipment.

Others, however, did identify what they considered to be impacts on the child's rights and wellbeing. This again included issues related to the rights of young parents and for the children of refugees and asylum seekers.

In relation to the young parents, two respondents felt their rights were undermined or ignored by the proposal to make payments to the grandparent:

"We do not think this complies with a rights based approach. In line with promoting and protecting children's rights, the parent, regardless of their age, should be the eligible person." (Organisation)

"In some circumstance it may be that it is easier to evidence the requirement to be habitually resident in a claim in the name of the grandparent, as they are in receipt of the appropriate qualifying benefit. However, it may be desirable that the young person is able to receive the new Best Start Grant and as such an option on the claim form to enable a payment to the young person may be a solution." (Organisation)

Two others raised issues related to refugees and asylum seekers, with one questioning the impact on refugees, and another seeking clarification from the Scottish Government around the level of consultation with/consideration given to this group when drafting the regulations:

"It seems unfair that families who have refugee status - having no recourse to public funds yet are living in the country do not receive this grant." (Individual)

"[We] propose that the Scottish Government seeks to gather evidence about the numbers and life circumstances/experiences of children living in families seeking asylum and who reside in Scotland. The aim being to ensure that all children in Scotland have the very best start in life, and to support activities associated with the Best Start Grant; Child Poverty (Scotland) Act 2017 (Scottish Parliament 2017); and the Scottish Government's proposed Connected Scotland: Tackling Social Isolation and Loneliness Strategy (Scottish Government, 2018). [We] would also be keen to establish if children who live within families who are seeking asylum have been included and consulted by the Scottish Government in relation to the Best Start Grant, and were given equal opportunities to have their views heard." (Organisation)

One respondent also highlighted that the lower amount paid to subsequent children could be discriminatory, and thus not provide all children with equal rights:

"The BSG is dependent on birth order of children. Where the first child received £600, the second child receives £300. This could be considered to be discriminatory based on birth order." (Organisation)

This respondent also, again, stressed the need for care experienced parents not to require a qualifying benefit:

"Research [has] highlighted the negative experiences of many care experienced young people and adults in trying to navigate the complex social security system that they disproportionately need to rely on compared to their peers. Scotland now has a unique opportunity to develop a social security system that is fair, respectful and just in its provision for care leavers. We continue to argue for an assumption of entitlement so care experienced parents do not require a qualifying benefit." (Organisation)

BSG Business and Regulatory Impact Assessment

The BSG Business and Regulatory Impact Assessment indicated that there could be impacts to businesses due to individuals having the spending power to buy items they could not otherwise have purchased. They noted that the impact would be dispersed across the country and different sectors of the economy. Expectations were also outlined around the potential for increased requests for information and support from existing advice services, and the need for close partnership working to provide a "seamless customer experience".

Q11. Can you identify any business related impacts not identified?

Response	Number	Percentage
Yes	2	4%
No	29	57%
Don't Know	4	8%
No quantitative response	16	31%
Total	51	100%

Most respondents did not identify any additional business related impacts, although a few did (largely those who stated yes or gave no response to the quantitative element, although one respondent who stated no also then went on to provide contradictory qualitative comments).

One respondent highlighted that the success of the BSG will be reliant upon effective sharing of data with DWP and noted that this may create difficulties which would limit the opportunities for automated payments. They also suggested that consideration should be given to the Scottish based Council Tax Reduction providing a qualifying benefit, and that an additional logical step would be to develop this into a single application process for any income related entitlement managed by local authorities ( e.g. including school meals and school clothing grants):

"There is a lot of data contained within Council Tax Reduction ( CTR) claims that could potentially identify households that qualify for the nursery/early years payment and school payment. As CTR is a Scottish Government scheme administered by local authorities then consideration should be given to allowing a claim for CTR to also serve as a claim for best start grant, but only in so far as it contains all the information required to make such a decision. There would then need to be a mechanism to either export the data of those who qualify to the Scottish Social Security Agency or to enable payments to be made locally on behalf of the Scottish Government." (Organisation)

Another respondent detailed potential benefits of enabling people to build and own their own 'Digital Identity' to offer evidence of eligibility and felt that a more positive stance in promoting the online identity of citizens was needed. They outlined potential partners who could assist in the development of this, and discussed the specific benefits such an approach could have in supporting social security benefits, including reducing stigma around the receipt of benefits.

One organisation highlighted that the Business Impact Assessment does not appear to take account of the training that may be required across a range of agencies (including support organisations, voluntary organisations, advice agencies and front-line customer service departments). They noted that advice agencies will require detailed training on the eligibility criteria and application process, while wider awareness raising will be required across community based services in order to ensure effective signposting and uptake of the grant.

Two organisations also noted (in agreement with the Business and Regulatory Impact Assessment) the potential for a sharp increase in the number of enquiries to advice agencies. This was, in part considered likely due to the timing of the BSG roll-out - potentially coinciding with Universal Credit and Personal Independence Payment roll-out/migration plans, although one of the organisations also outlined a range of other contributing factors as well.

Finally, the respondent who indicated 'no' to the quantitative element of this question but provided qualitative comment sought to reiterate the need to protect public funds, that they considered the BSG to be too generous, and there was no way to guarantee the monies would be used for the intended purposes.